Case Summary (G.R. No. 134117)
Applicable Law
This case is governed by the provisions of the 1987 Philippine Constitution, relevant statutes including the Civil Code of the Philippines, and Republic Act No. 1162 concerning expropriation and Presidential Decree No. 1517 pertaining to urban land reform.
Background of Property Transactions
The two parcels of land were originally owned by Sofia P. Martinez, who leased them to Yu Siong, the father of the president and stockholders of Sen Po Ek, for a commercial building that would revert to her ownership after the lease. The lease was renewed multiple times, ultimately expiring in January 1987, after which Sen Po Ek retained possession. Sofia sold the property to her daughter Teodora in 1979, but the deed was only notarized in 1985.
Notice of Intention to Sell
After Sofia's death, Teodora, on November 11, 1989, sent a letter to Sen Po Ek, indicating her intention to sell the property. However, this letter was received by Sen Po Ek on December 12, 1989. Teodora later sold the property to the Tiu Upying brothers on January 12, 1990, for P800,000.
Legal Proceedings and Trial Court Decision
Sen Po Ek filed for annulment of the deed of sale on the grounds of a right of first refusal under the Urban Land Reform Law. The trial court sided with the petitioner, rescinding the sale to the Tiu Upying brothers and affirming Sen Po Ek's preferential right to purchase the property.
Court of Appeals Decision
The Court of Appeals reversed the trial court’s decision. It concluded that the sale to Teodora was a valid transaction, as the lower court could not annul a deed that neither Sofia nor her heirs contested. The appellate court found that the claim of a right of first refusal was unfounded, emphasizing that Sen Po Ek did not qualify as an adjoining owner or tenant as defined under the applicable laws.
Analysis of Pre-emption Rights
The petitioner's argument for a right of first refusal was dismissed by the Court of Appeals. The ordinances cited, namely P.D. No. 1517 and R.A. No. 1162, were not applicable since the properties were not in an urban land reform zone or under those laws' prescribed expropriation provisions. Furthermore, there was no evidence of a contractual basis granting Sen Po Ek any preferential rights to purchase the property.
Final Holding
The Supreme Court upheld the Court of Appeals decision. It confirmed that the initial sale to Teodo
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Case Background
- The case involves a petition for review on certiorari filed by Sen Po Ek Marketing Corporation against private respondents Teodora Price Martinez and her brothers Juanito, Nelson, and Leoncio Tiu Uyping.
- The petition challenges the Decision and Resolution of the Court of Appeals dated October 13, 1997, and May 18, 1998, which reversed the Regional Trial Court's (RTC) rescission of a Deed of Absolute Sale concerning two parcels of land.
- The lands in question were originally owned by Sofia P. Martinez and were subject to a lease agreement with Yu Siong, the father of the petitioner’s president and stockholders.
Facts of the Case
- Sofia P. Martinez was the registered owner of two parcels of land in Tacloban City under Transfer Certificate of Title No. 2915.
- The lease of the properties began on October 25, 1961, with an obligation for the lessee to construct a commercial building, which later became subject to the ownership rights of Sofia after lease expiration.
- After Sofia sold the properties to her daughter, Teodora, in 1979 (notarized in 1985), Teodora attempted to sell the properties following Sofia's death in 1989.
- Teodora sent a letter on November 11, 1989, expressing her intention to sell the properties, which was received by Sen Po Ek on December 12, 1989.